G.R. Nos. L-32951-2. September 17, 1971 (Case Brief / Digest)

### Title:
**Ricardo de la Camara vs. Hon. Manuel Lopez Enage: A Case on Excessive Bail**

### Facts:
Ricardo de la Camara, the Municipal Mayor of Magsaysay, Misamis Oriental, was arrested on November 7, 1968, and detained for his alleged role in the killing of fourteen and wounding of twelve laborers on August 21, 1968. Charges for multiple frustrated murder and multiple murder were filed against him and his co-accused. On January 14, 1969, de la Camara sought bail, claiming innocence and lack of evidence linking him to the crime. After the prosecution rested its case, on August 10, 1970, the trial judge granted bail but set the amount at P1,195,200.00, prompting an appeal for reduction which was refused. De la Camara then filed a petition for certiorari in the Supreme Court, challenging the excessive bail. His subsequent jailbreak while the petition was pending rendered the case moot, but the Supreme Court took the opportunity to elucidate on the principles governing the setting of bail.

### Issues:
1. Whether the bail amount set by the respondent judge was excessively high, violating constitutional prescriptions against excessive bail.
2. Whether the Supreme Court has the authority to intervene in the trial court’s discretion in setting bail amounts.
3. The legal implications of the petitioner’s escape from jail on the resolution of the case.

### Court’s Decision:
The Supreme Court, recognizing the moot nature of the case due to the petitioner’s escape, did not rule directly on the merits of reducing the bail amount but took the opportunity to articulate the principles and guidelines to ensure that bail is not set at an excessive level. The Court emphasized that bail should not be set at an amount that negates its purpose, which is to ensure the defendant’s presence at trial while respecting their right to presumption of innocence. The Court criticized the trial judge’s decision to set bail at P1,195,200.00 as clearly violative of the constitutional provision against excessive bail. However, since de la Camara escaped, the Court dismissed the case as moot but reiterated the fundamental principles related to bail.

### Doctrine:
The Supreme Court set forth doctrines emphasizing that (1) bail should not be excessive and must consider the financial capability of the accused; (2) the right to bail is fundamental and should not be nullified by setting prohibitively high bail amounts; and (3) while judges have discretion in setting bail, this discretion is bounded by constitutional and legal standards to prevent excessive bail.

### Class Notes:
– **Presumption of Innocence and Bail:** Every person is presumed innocent until proven guilty. Before conviction, the right to bail is secured except in cases involving capital offenses when evidence of guilt is strong.
– **Excessive Bail:** Bail is considered excessive when it goes beyond an amount reasonably calculated to ensure the accused’s appearance in court.
– **Judicial Discretion in Setting Bail:** Judges have discretion in setting bail amounts, guided by factors including the severity of the offense, the accused’s financial capacity, character, and risk of flight. However, this discretion is not absolute and must align with constitutional guarantees against excessive bail.
– **Role of the Supreme Court:** The Supreme Court has supervisory powers to correct excessive bail amounts set by lower courts to uphold constitutional rights.

### Historical Background:
This case, arising during the late 1960s in the Philippines, emphasizes the tension between judicial discretion in bail settings and constitutional mandates against excessive bail. It reflects the Supreme Court’s role in interpreting constitutional provisions to guide lower courts, ensuring that rights to reasonable bail and the presumption of innocence until proven guilty are upheld.


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